The Department of Justice reports that a Guatemalan company has paid more than $118 million to resolve an investigation into a long-running scheme to bribe government officials in that country. This company is a wholly-owned subsidiary of a business headquartered in Luxembourg that has its principal place of business in the U.S.
A DOJ press release states that between 2012 and 2018 the company “engaged in a widespread and systematic bribery scheme” that featured monthly bribe payments to numerous Guatemalan members of Congress or members of their security teams in exchange for, among other things, their support for legislation that benefited the company.
According to a DOJ press release, the company entered into a two-year deferred prosecution agreement to resolve charges of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act. As part of this DPA the company agreed to pay a $60 million criminal penalty and $58.2 million in administrative forfeiture. In addition, the company and its corporate parent agreed to (1) continue cooperating with the DOJ in any ongoing or future criminal investigation arising during the term of the DPA and (2) enhance the company’s compliance program and periodically report to the DOJ on their remediation and implementation of compliance measures.
The DOJ notes that (1) aggravating factors included the company’s continuation of its criminal conduct during and after an initial DOJ investigation and (2) mitigating factors included proactively disclosing some evidence and engaging in extensive timely remedial measures, including introducing new and experienced management and compliance personnel to change the culture of compliance, quickly incorporating key compliance policies and procedures, and significantly restructuring, expanding, and resourcing the parent company’s global compliance program.
Earlier this year the DOJ announced updated guidelines on FCPA enforcement that emphasized prosecutions of individuals, among other things.
Copyright © 2026 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.